ML15356A185

ANP-3456NP, Revision 0, Response to SLU2 NRC Snpb RAI-9, Licensing Report.

ML15356A185
Person / Time
Site:	Saint Lucie
Issue date:	12/31/2015
From:	AREVA
To:	Office of Nuclear Reactor Regulation
Shared Package
ML15356A251	List: L-2015-300, ANP-3352NP, Revision 1, Transition License Amendment Request, Technical Report. ML15356A184 ML15356A185
References
L-2015-300, TAC MF5494, TAC MF5495 ANP-3456NP, Rev. 0
Download: ML15356A185 (35)

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L-2015-300Attachment 3ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensing ReportFollowing 31 pages III kJU~U LJ~JL~UI I~I ILA RE EVAResponse to SLU2 NRC SNPB RAI-9Licensing ReportAN P-3456N PRevision 0December 2015AREVA Inc.(c) 2015 AREVA Inc.

'.,LJI ILl UI[~U L/LJUUI I I~I ILANP-3456NPRevision 0Copyright © 2015AREVA Inc.All Rights Reserved

~~IJI [LI L/lI~U LJUL'UI I I~I ILAREVA Inc.AN P-3456N PRevision 0Response to SLU2 NRC SNPB RAI-9Licensina ReoortPaae iNature of ChangesItem1Section(s)or Page(s)AllDescription and JustificationInitial Issue

.;L,.U 1 IIl U.fiI t~i L.JUL,.7L.AI.i I I1.AREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAi-9Licensing Report Page iiContentsPage1.0 INTRODUCTION...................................................................... 1-12.0 RESPONSES TO NRC QUESTION ................................................ 2-12.1 NRC SNPB RAI-9............................................................. 2-13.0 REFERENCES........................................................................ 3-1

'AJ1 U! I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensinqi Report Paqie iiiList of TablesTable 2-1 Seismic and LOCA Loadings................................................... 2-3Table 2-2 Maximum Seismic and LOCA Impact Loads by Row Pattern................ 2-4Table 2-3 Maximum Vertical Impact Loads.............................................. 2-21 AREVA Inc.Response to SLU2 NRC SNPB RAI-9Line~nsina Renort:ANP-3456NPRevision 0Paae ivFigure 2-1Figure 2-2Figure 2-3Figure 2-4Figure 2-5Figure 2-6Figure 2-7List of Figures17 Assembly Row Reactor Core Reload Pattern ............................ 2-615 Assembly Row Reactor Core Reload Pattern ............................ 2-713 Assembly Row Reactor Core Reload Pattern ............................ 2-811 Assembly Row Reactor Core Reload Pattern ............................ 2-99 Assembly Row Reactor Core Reload Pattern ............................ 2-104 Assembly Row Reactor Core Reload Pattern ............................ 2-11Fuel Assembly Vertical Model Schematic................................... 2-22

~..jIjI III ~JII~U LJLJLUI I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensinqi Report Paqe 1-11.0 INTRODUCTIONThis document contains the response to NRC SNPB RAI Question 9. The request is asfollows:"The following questions are related to the seismic and seismic/LOCA evaluations ofAREVA CE 16x16, HTP, co-resident CE 16x16 and mixed core at SLU-2 associatedwith its request for introduction of the new fuel. They are based on the relevant sectionsof ANP-3352P and ANP-3396P that were submitted to the NRC.a. ANP-3396P, Section 3.2 indicates that "for St. Lucie Unit 2, the events wereanalyzed for a full core of the current fuel design, a full core of the AREVA CE16x16 HTP fuel, and for a wide range of mixed core configurations, in order toverify that the limiting loads and deflections remain within acceptable fuel designlimits." Provide a summary of the results from the above-mentioned analyses forthe three different configurations of the SL-2 core.b. TR BAW-10133(P)(A) originally modeled a Mark-C fuel assembly for seismic andLOCA analyses. The licensee claims that the Addenda I and 2 of this TR hasdemonstrated its acceptability for other generic pressurized-water reactor fuelassembly designs, including the CE 16x16 HTP fuel design. Table 3.1 of ANP-3396P for Nominal Beginning of Life (BOL) Mechanical Design Data Comparisonindicates significant differences in several listed parameters for CE I16x1 6 HTPand Mark-C fuel designs. Therefore, explain in detail how the differences areaccounted for in the components testing."c. ANP-3396P states that additional testing and evaluations are included in theanalyses to address this NRC Information Notice (IN) 2012-09. Provide detailedinformation on testing performed in response to IN 2012-09.d. Provide a detailed description of both the L] that are mentioned in the ANP-3396P report. Provide theresults from the analysis that used the [] and explain in detail."

L.#IJI ILl ~JEI~U LJULiUI I I~I ILAREVA Inc.Response to SLU2 NRC SNPB RAI-9Licensinq ReportNote:ANP-3456NPRevision 0Paqe 1-2]The information provided in ANP-3396P remains unchanged. However, the newanalyses affect some of the information in ANP-3352P, Revision 0, as identified in therevised report ANP-3352P, Revision 1, which has been revised to show the revisedresults. The analytical methods described and the conclusions of ANP-3352P, Revisiono are unchanged. The AREVA design continues to meet the design requirements forboth the transition cores and the full cores. The responses presented in this RAIresponse, particularly part (a), also reflect the updated analysis. After resolution of thisissue, it was determined that ANP-3396P [2] was unaffected.

'~.jLJE IL! LJII~U LJULUI I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9LicensinIq Report Paqe 2-12.0 RESPONSES TO NRC QUESTION2.1 NRC SNPB RAI-9Question # SNPB RAI-9 (a):."ANP-3396P, Section 3.2 indicates that "for St. Lucie Unit 2, the events were analyzedfor a full core of the current fuel design, a full core of the AREVA CE 16x16 HTP fuel,and for a wide range of mixed core configurations, in order to verify that the limitingloads and deflections remain within acceptable fuel design limits." Provide a summaryof the results from the above-mentioned analyses for the three different configurationsof the SL-2 core."Response:The purpose of the analyses performed by AREVA is to evaluate the AREVA fuelagainst the safety criteria required for licensing. As such, the analyses not onlyconsider the eventual scenario in which the core is fully loaded with AREVA fuel, butalso considers those transition (or mixed) cores as AREVA fuel is introduced. Therepresentation of the co-resident fuel in AREVA's mixed core analyses is made usinginputs (e.g. fuel assembly dynamic characteristics and spacer grid impactcharacteristics) provided by the fuel vendor via the Licensee. This representation of theco-resident fuel is adequate to assess the performance of AREVA's fuel design.

'..AJI ILl LJlI~U LJLJL'UI I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9LicensinQ Report Paae 2-2Six row models were established to represent the different row lengths present in the St.Lucie Unit 2 core: 4-, 9-, 11-, 13-, 15-, and 17-assembly rows. Each row model wasanalyzed considering a full row of AREVA fuel in addition to various patterns of mixedrows with both AREVA and co-resident fuel. The various patterns provide the behaviortrends due to the positions of the different fuel types. For the mixed core configurationat St. Lucie 2, the limiting load condition for either the AREVA or co-resident fuel [] The results of the various loading patterns in each row providethe basis for identifying the most limiting conditions.For the St. Lucie Unit 2 analyses, a total of [ ] fuel assembly core patternswere ultimately analyzed and these are shown in Figures 2-1 through 2-6. These rowpatterns are sensitivity studies addressing the different assembly types in various corelocations. Note that the letters "A" and 'LWr' in these figures represent the locations ofthe AREVA CE 1 6x1 6 and co-resident fuel assemblies, respectively. Each row modelwas subjected to the full set of seismic and LOCA loadings required for St. Lucie Unit 2.The analytical methodology used for the analyses is based on the methods described inBAW-10133PA, Rev. 1, including Addenda 1 and 2 [3].The maximum grid impact forces on the AREVA fuel for both LOCA and seismicaccidents occur [] The results of these limiting cases are summarized below. Based on theevaluations performed, for both seismic (OBE and SSE) and LOCA events, the AREVAfuel assemblies meet design limits for both mixed core and full core conditions.Table 2-1 provides the results for the limiting cases and Table 2-2 shows the loads forall the row configurations analyzed.

AREVA Inc.Response to SLU2 NRC SNPB RAI-9Licensincq ReportANP-3456NPRevision 0Paqie 2-3Table 2-1 Limiting Seismic and LOCA LoadingsLoad !Allowable IMargin Ro Layout.................... ii F 1* ' 9 &1 5 assem blyFull BLL J 8 oCoeI New AA AEOL 7 1[°/°1%* 1 assembly row4Coe[O ] [ 37CoLe[L]' [ ] 7o0 11 assembly row___I..I IAWW...WWACoeV EOL r 1 1 [ 1 043%* 17 assembly row_ ___J L IL JAWAW...WAWAA* This allowable limit has been updated from the value initially reported in Revision 0 ofANP-3352P based on the inclusion of additional crush test data for the St. Lucie 2specific grid type.** This margin (14%) is based on the simulation of an unrealistic core loading pattern inwhich fresh AREVA fuel is placed directly on the baffle while the rest of the core ispopulated by non-AREVA fuel. This row configuration, while unrealistic, was analyzedfor conservatism. Without this row configuration, the next limiting mixed coreconfiguration yields 60% margin (Case 170 in Figure 2-1).**In general, the mixed core cases indicate significantly lower margins than the fullcore cases. These margins are reduced because of additional conservatisms includedin the mixed core cases to assure uniform treatment of different assembly types. Inparticular, all fuel assembly damping values for the mixed core cases wereconservatively set to match the co-resident fuel. Using this damping for the AREVA fuelis very restrictive and is less than half of the damping that is approved for use in BAW-10133P-01, Addendum 2. The impact of this additional conservatism can be seen inthe order of magnitude difference between full core and mixed core margins.

~jt.JI ill LJ!I~U LJ~JLiLI[ I I~I ~LAREVA Inc.ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensina RenortP~ri_ 2-4Table 2-2 Maximum Seismic and LOCA Impact Loads by Row Pattern*,**Notes:* SSE + LOCA loads are calculated by performing a square root sum of squares(SRSS) combination of the individual SSE and LOCA loads shown here.**[I

~..#LJI III LJII~U LJULiUI I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensingq Report Paqe 2-5Co-Resident Fuel EvaluationTo support the evaluation of the co-resident fuel, AREVA's analyses also provided inputon the relative effect that AREVA fuel has on the response of the co-resident fuel. Forthis evaluation, AREVA first analyzed row models consisting entirely of co-resident fuel.The analysis of these row models provided a baseline against which to provide acomparison. The impact loads in the co-resident fuel assemblies in the mixed coreconfigurations, in comparison to the baseline impact loads, provided a relativeassessment of the effect of AREVA fuel on the co-resident fuel. [J This information was provided to FPLfor their evaluation of the co-resident fuel.The evaluation performed by Westinghouse for the Westinghouse co-resident fuelassemblies under the seismic/LOCA loadings associated with mixed core configurationsof AREVA and Westinghouse fuel, using the above load increase, demonstrated thatthe Westinghouse fuel assemblies would continue to satisfy the applicableseismic/LOCA design criteria consistent with the licensed methodology of CENPD-1 78and its associated SER [6].

'~JLJI ILl UU~U LJUL'U[ I C~I ILAREVA Inc.Response to SLU2 NRC SNPB RAI-9Licensino ReoortANP-3456N PRevision 0Pacie 2-6Figure 2-1 17 Assembly Row Reactor Core Reload Pattern

'..iUi ILl !JlE~U LJU~.jUI I I~I ILAREVA Inc.AN P-3456N PRevision 0Response to SLU2 NRC SNPB RAI-9Licensina RenoartPRaR 2-7Figure 2-2 15 Assembly Row Reactor Core Reload Pattern

'...#LJI ILl LJII~U LJUL~UI I I~I ILAREVA Inc.Response to SLU2 NRC SNPB RAI-9Licensina RenortANP-3456NPRevision 0Paqie 2-8Figure 2-3 13 Assembly Row Reactor Core Reload Pattern

'~LII III ~JII~U L/'JLUI I l~I iiARE VA Inc.AN P-3456N PRevision 0Response to SLU2 NRC SNPB RAI-9Sicn~nsina1 RennrtPRn~ 2-9Figure 2-4 11 Assembly Row Reactor Core Reload Pattern

'.j~.JI ILl 1JII~U LJIJLUI I I~I ILAREVA Inc.AN P-3456N PRevision 0Response to SLU2 NRC SNPB RAI-9Licensinq ReportP~nri 2-1OFigure 2-5 9 Assembly Row Reactor Core Reload Pattern

~..jLJI III LJ1I~U LJLJL~U! I I~I ILAREVA Inc.Response to SLU2 NRC SNPB RAI-9Sir.ens~inr ReportAN P-3456N PRevision 0Paae 2-11Figure 2-6 4 Assembly Row Reactor Core Reload Pattern AREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensingq Report Paqe 2-12Question # SNPB RAI-9 (b):"TR BAW-10133(P)(A) originally modeled a Mark-C fuel assembly for seismic andLOCA analyses. The licensee claims that the Addenda 1 and 2 of this TR hasdemonstrated its acceptability for other generic pressurized-water reactor fuel assemblydesigns, including the CE 16x16 HTP fuel design. Table 3.1 of ANP-3396P for NominalBeginning of Life (BOL) Mechanical Design Data Comparison indicates significantdifferences in several listed parameters for CE 16x16 HTP and Mark-C fuel designs.Therefore, explain in detail how the differences are accounted for in the componentstesting."Response:The BAW-10133(P) (A) topical report, although referencing the Mark-C design in thetitle, describes the general methodology, which is structured to be generically applicableto PWR fuel designs. The generic methodology requires that the specific fuel assemblybe tested to determine the dynamic behavior. A finite element model is then createdand benchmarked to these design specific test results. Thus a design specific fuelassembly model is established. Plant specific time histories are used with thisbenchmarked finite element model to determine the fuel assembly displacements andimpact loads. These calculated loads are then compared to the design limits todetermine the acceptability of the design. The applicability to the different PWR fueldesigns is provided by the design specific fuel assembly test results, and the plantspecific applicability is provided by the plant specific time histories. The genericapplicability is captured in the Safety Evaluation Report (SER) for BAW-10133(P) (A),Rev. 1 in which it is noted that the methodology is acceptable for the "Mark C fueldesign and similar designs". The methodology was modified in Addendum 1 where it isstated that "the application of this method is for generic use". Addendum 2 introducesthe damping values to apply in this analysis and is noted to be "justified for all FCF(AREVA) PWR fuel designs based on the supporting test data".

'..jUI iLl LJll~U LJULUI I I~l ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensincq Report Paqie 2-13Consistent with the stated intent of the method given in TR BAW-10133PA (withAddenda 1 and 2) [3] to be generic, the described methods given in ANP-3396P [2] andANP-3352P [1] are appropriate to the CE 16x16 HTP design being analyzed. BAW-10133PA (with Addenda 1 and 2) defines generic finite element model architecture andtesting protocols that can represent the structure of any PWR fuel assembly. Designspecificity is introduced in the characterization of the fuel through testing and thedefinition of model parameters that define assembly behavior, such as bundle stiffness,frequency, etc. Plant specificity is introduced in the geometry of the model boundaryconditions (core dimensions, fuel assembly pitch, etc.) and inputs (e.g., core plateseismic and LOCA time histories). The application of BAW-10133PA (with Addenda 1and 2) is thus justified for CE 16x16 fuel when fuel design specific bundle/componenttesting and model benchmarking is performed and the model parameters are derivedfrom those tests. AREVA conducted full fuel bundle assembly tests and componenttests of the St. Lucie 2 AREVA design. FPL provided the St. Lucie Unit 2 time histories.A description of the CE 16x16 HTP design, along with other designs where BAW-10133(P) (A) has been applied, is presented in Table 3.1 of ANP-3396P. The buildingblock of the lateral model is a simplified single column fuel assembly model. The singlefuel assembly model is benchmarked against dynamic vibration test results in both BOLand EOL conditions. This process of benchmarking of the single fuel assembly modelis the same regardless of the type of the PWR fuel design. The single fuel assemblymodel is benchmarked to [J After asingle fuel assembly beam model is benchmarked against the results of design-specificfuel assembly characterization tests, it is available for use in licensing analyses of thecore. The characterization tests and the model parameters derived from those testsare the same as described in TR BAW-10133PA (with Addenda 1 and 2) regardless ofthe type of the PWR design. Small design differences such as guide tube, fuel rod andthe instrument tube cross section properties, number of grids, grid span length, numberof grids, number of guide tubes and fuel rods, material, etc. are ultimately homogenized

'~.iUI III ~J~I~U LJ'..J~iUI I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensincq Report Paqie 2-14in the overall dynamic characterization of the fuel bundle, based on full-scale bundletesting. All models used in the fuel assembly seismic and LOCA analyses arebenchmarked to these overall, design-specific characteristics that are defined throughtesting and as such, they are appropriate for representation of the fuel assembly. It isnoted in Table 3.1 of ANP-3396P that there are only small differences in the fuelassembly 1st mode natural frequencies between the Mark-C and the CE 16x16 fuelassembly [ ]The spacer grid dynamic properties, needed to simulate the grid response underimpacts during seismic and LOCA events, are also obtained from design specific tests.These tests are generically defined in BAW-10133PA, Rev. 1, Addendum 11[3]. Thistesting also establishes a design-specific definition of grid allowable load limits. Thespacer grid properties used in the lateral core model are benchmarked to design-specific test data and as such, they are appropriate for representation of this fueldesign.

~...AJI ILl UII~U L.JUL,'LII I I~I ILAREVA inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensingq Rep~ort Paqe 2-15Question # SNPB RAI-9 ('c)"ANP-3396P states that additional testing and evaluations are included in the analysesto address this NRC Information Notice (IN) 2012-09. Provide detailed information ontesting performed in response to IN 2012-09."Response:In response to IN 2012-09, additional testing and analyses were performed to evaluatethe SLU2 fuel design. In particular, characterization tests (free and forced vibration)done on full scale fuel assemblies were performed for two St. Lucie Unit 2 designspecific test assemblies, one representing the non-irradiated, or beginning-of-life,condition and the other representing the irradiated, or end-of-life, condition. Similarly,characterization testing of individual spacer grids was performed on grids in both thenon-irradiated and a simulated-irradiated condition. This test data was used to developseparate models that represent the fuel in both non-irradiated and irradiated conditions.Likewise, analyses were performed to consider the fuel response in both the non-irradiated and irradiated conditions.To simulate the effects of irradiation on overall fuel assembly characteristics duringdynamic characterization testing, (] Thedynamic characterization testing is performed following the same protocol for both non-irradiated and simulated-irradiated fuel assemblies. In comparison to the testsperformed on the non-irradiated fuel assembly, ['

~.jIJI ILK LJII~U LJU~iL~I I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensinq Report Paqe 2-16The effects of irradiation are also simulated in the spacer grid impact testing. Thegeneral methodology for the spacer grid dynamic impact testing is established anddefined in Addendum 1 of BAW-10133PA. The spacer grid dynamic impact testing wasperformed for both non-irradiated and simulated-irradiated configurations using thistesting protocol, but L J to simulate the effects of irradiation.J It has been demonstrated based on testing conducted in a hotcell on actual irradiated grids, that []

IU ~ ~ I PAREVA Inc.Response to SLU2 NRC SNPB RAI-9LicensinQ RepjortANP-3456NPRevision 0Page 2-17II] This protocol hasbeen shown to demonstrate a good, conservative agreement with the results of thetests performed on irradiated grids in the hot cell.

~JIJI III '...JII~U LJIJL~UI I I~E ILAREVA Inc.Response to SLU2 NRC SNPB RAI-9Licensingq ReportQuestion # SNPB RAI-9 (d):ANP-3456NPRevision 0Paqe 2-18"Provide a detailed description of both the [] that are mentioned in the ANP-3396P report. Provide the results from theanalysis that used the [ ] and explain in detail."Response:The vertical response of the AREVA St. Lucie Unit 2 fuel assembly due to the verticalLOCA loads was determined using I" ]. This [] approach is awhich a [modification to the method described in BAW-1 01 33(P)(A), inJ is described. The [IIn contrast, the [I

'~.AjI ILl ~JCl~U LJULjUE I C~E ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensinq Rep~ort Paqe 2-19[IA [ ] uses two columns representing the guide tubes and the fuelrods. These columns are modeled as linear translational springs. All nodal degrees offreedom (DOFs) in the lateral and rotational directions are constrained and hence, noextraneous reaction forces or moments are produced. Furthermore, a third column isadded to the model to represent an instrument tube. The spring element characteristicsare directly derived from geometric and material considerations except for the tie plateswhose stiffnesses are derived from design-specific component testing. The hold-downspring force is accounted for by using a linear translational spring element. In addition,the nonlinear capabilities of the model consist of a number of gap-springs, gapdampers, and slider elements, as shown in Figure 2-7. A brief discussion of theseelements follows:*The non-linear gap-spring-damper element representing the lower tie plate: Thestiffness of this element is used to account for the stiffness of the load-path betweenthe guide tube connections and the lower core plate for the Beginning of Life (BOL)case, and from the lower tie plate upper face and the lower core plate for the End ofLife (EOL) case. In the EOL case, the load is distributed on the upper face of thelower tie plate, since the fuel rods are resting against this surface. This element hasdamping capability, which is necessary to accurately capture the fuel assemblyrebound height in the case of an impact. The input parameters for this element arebenchmarked using results from an axial drop test performed on the SLU-2 CE

'~~AJI IL! ~JII~U LJLJLUI I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensincq Report Paqie 2-2016x16 fuel assembly design.*The non-linear gap-spring-damper element between the fuel rod lower end and thetop face of the lower tie plate: The element gap is a function of the fuel design andBOL or EOL condition. In the BOL condition the gap is open for the CE 16x16 HTPdesign. In the EOL condition the gap is closed due to the subsequent seating of therods on the upper face of the lower tie plate and the impact load is carried throughthe stiffness of the lower tie plate grillage. The input parameters for this element arebenchmarked using results from an axial drop test performed on the SLU-2 CE16x16 fuel assembly design.*The non-linear gap-spring-damper element between the top of the fuel rods and theupper tie plate: The characteristics of this spring are similar to the element above,with the gap being different. This gap is designed to remain open over the servicelife of the fuel assembly under normal operating conditions (including irradiationgrowth), but could close due to impacts produced by seismic or LOCA loading. Theinput parameters for this element are benchmarked using results from an axial droptest performed on the SLU-2 CE 16x16 fuel assembly design.*The non-linear slider elements between the fuel rod nodes and the correspondingspacer grid nodes on the guide tube column: These elements are characterized bystiffness (or slope) and a saturation force at which the fuel rods begin to slip withinthe spacer grids (i.e. the grid slip load). The input parameters for this element arebenchmarked using the slip loads measured from tests performed on SLU-2 CE1 6x1 6 HTP spacer grids and test results from axial stiffness tests performed on theSLU-2 CE 16x16 fuel assembly.The vertical load analysis is performed on a single fuel assembly model by applying theseismic or LOCA loads in the vertical (axial) direction. The vertical fuel assembly modelcalculates the axial loads primarily arising from fuel assembly impacts with the upperand lower core plate during seismic and LOCA excitations. From the vertical faultedcondition analyses for CE 16x16 HTP fuel at St. Lucie Unit 2, the maximum impactloads are reported in Table 2-3.

ILl LJII~U LJLJLUI I I~I ILAREVA Inc.ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensino ReportPaae 2-21Table 2-3 Maximum Vertical Impact LoadsMaximum Impact Load [N] BOL EOLLOCA [ ][ JThe resulting axial loads are combined with loads from the normal operating andhorizontal load analyses for subsequent component stress and structural integrityanalysis, as reported in ANP-3352P [1]. These combined loads are then evaluatedusing the ASME derived limits. The St. Lucie 2 design has margin to these ASMEderived limits.

III LJhI~U LJLJLLH I I~I ILAREVA Inc.ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensinq ReoortPaae 2-22Figure 2-7 Fuel Assembly Vertical Model SchematicHeight20U-(28K27K26C2.5UI-03C03UK25K24mK23rnK22KG4 = Preloaded Hold-Down + UTPSpring: KG3 = UTP to FR UEPK2oSK17ml.3SK15FS6lm3K1613rns n K1254:K2=FR LEP to LTPKG1 =LTP to Core SupportPlateK21 .m2626C2xI-0)CYSK2Node NumberLinear Spring Element Number K1Lumped Mass ElementsSlider Friction ElementsNon-Linear Spring Element Number1 TLower Core Support Plate

~..iUi ELI ~JII~U LJLJLiUI I I~I ILAREVA Inc. ANP-3456NPRevision 0Response to SLU2 NRC SNPB RAI-9Licensinqi Report Paqe 3-13.0 REFERENCES1. ANP-3352P, Revision 1, St. Lucie Unit 2 Fuel Transition LicenseAmendment Request Technical Report, November 2015.2. ANP-3396P, Revision 0, St. Lucie Unit 2 Fuel Transition SupplementalInformation to Support the LAR, March 2015.3. Topical Report, BAW-10133PA, Rev. 1, Addenda 1 and 2, 43-10133PA-00, 04/99.4. ANP-10337P, Revision 0, PWR Fuel Assembly Structural Response toExternally Applied Dynamic Excitations Topical Report, August 2015.5. BAW-10172(P)(A), Revision 0, "Mark-BW Mechanical Design Report"6. Topical Report CENPD-178-P, Revision l-P, "Structural Analysis of FuelAssemblies for Seismic and Loss of Coolant Accident Loading" andassociated SER letter from H. Bernard (NRC) to A. E. Scherer (C-E),"Acceptance for Referencing of Licensing Topical Report CENPD-1 78" L-2015-300Attachment 4Page 1 of 3A FF1 DAVITCOMMONW1EALTH OF VIRGINIA )) SS,CITY OF LYNCHBURG)1f. My name is Nathan E. Hottie. I am Manager, Product Licensing, for AREVAInc. (AREVA) and as such I am authorized to execute this Affidavit.2. I am familiar with the criteria applied by AREVA to determine whether certainAREVA information is proprietary. I am familiar with the policies established byAREVA to ensure the proper application of these criteria.3. I am familiar with the AREVA information contained in the following document:"ANP-3352P Rev. 1, St. Lucie Unit 2 Fuel Transition License Amendment Request," referred toherein as "Document." Information contained in this Document has been classified by AREVA asproprietary in accordance with the policies established by AREVA Inc. for the control andprotection of proprietary and confidential information.4. This Document contains information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA and not made available to thepublic. Based on my experience, I am aware that other companies regard information of thekind contained in this Document as proprietary and confidential.5. This Document has been made available to thie U.S. Nuclear RegulatoryCommission in confidence with the request that the information contained in this Document bewithheld from public disclosure. The request for withholding of proprietary information is made inaccordance with 10 CFR 2.390. The information for which withholding from disclosure is L-2015-300Attachment 4Page 2 of 3requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financialinformation."6. The foillowing criteria are customarily applied by AREVA to determine whetherinformation should be classified as proprietary:(a) The information reveals details of AREVA's research and development plansand programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly reduce its expenditures, in time or resources, to design, produce,or market a simfiar product or service.(c) The information includes test data or analytical techniques concerning aprocess, methodology, or component, the application of which, results in acompetitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitve advantage for AREVA in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA, would behelpful to competitors to AREVA, and would likely cause substantial harm tothe competitive position of AREVA.The Information in this Document is considered proprietary for the reasons set forth inparagraphs 6(c), 6(d), and 6(e) above.7. In accordance with AREVA's policies governing the protection and control ofinformation, proprietary information contained in this Document has been made available, on alimited basis, to others outside ARE VA only as required and under suitable agreement providingfor nondisclosure and limited use of the information.8. .AREVA policy requires that proprietary information be kept in a secured file orarea and distributed on a need-to-know basis.

L-2015-300Attachment 4Page 3 of 39. The foregoing statements are true and correct to the best of my knowledge,information, and belief.SUBSCRIBED before me this____Sherry L. MoFaden*NOTARY PUBLIC, COMMONWEALTH OF VIRGINIAMY COMMISSION EXPIRES: 10131118Reg. # 7079129, a, AA A A-- ......ItSHERRY L MCFADENNOIMVPUbkComn~~unIU~ of WginIa707912~omm~uh1oe ~xofrus Oct 31, 20%S